PTAB

IPR2017-00168

Oracle America Inc v. Realtime Data LLC

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1. Case Identification

2. Patent Overview

  • Title: System and method for lossless data compression and decompression
  • Brief Description: The ’812 patent discloses systems and methods for lossless data compression and decompression. The core technology combines two well-known techniques: run-length encoding for repeated data sequences and dictionary-based encoding, specifically a Lempel-Ziv-Welch (LZW) algorithm, for other data.

3. Grounds for Unpatentability

Ground 1: Claims 1, 9, 14, and 22 are obvious over Seroussi in view of Heath

  • Prior Art Relied Upon: Seroussi (Patent 5,389,922) and Heath (Patent 5,973,630).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner argued that Seroussi, which teaches a compression system combining run-length and LZW dictionary encoding, discloses most limitations of independent claims 1 and 14. Seroussi’s system includes a "run enhancement engine" that detects runs by identifying when sequential code words produced by its LZW encoder become "out of order," indicating a repetitive pattern. While Seroussi teaches run detection and outputs encoded runs, Petitioner cited Heath to supply more explicit teachings for certain limitations. Specifically, Heath was asserted to teach "detecting if the input data comprises a run-length sequence of data blocks" and, for dependent claims 9 and 22, the step of "bit-packing" the output code words to improve compression efficiency.
    • Motivation to Combine: A POSITA would combine Seroussi and Heath as both references are in the same field of data compression, address the same problem of improving dictionary-based compression, and propose the same solution of incorporating run-length encoding. Petitioner argued it would have been a predictable design choice to substitute Heath's explicit method of detecting runs and its well-known bit-packing technique into Seroussi's analogous system to improve performance and compression ratios.
    • Expectation of Success: A POSITA would have a reasonable expectation of success in combining the references, as applying a known technique like bit-packing (from Heath) to an output stream of variable-length codes (as produced by Seroussi) is a standard method to achieve better compression, a predictable and desired outcome.

Ground 2: Claim 28 is anticipated by Seroussi

  • Prior Art Relied Upon: Seroussi (Patent 5,389,922).
  • Core Argument for this Ground:
    • Prior Art Mapping: Petitioner asserted that Seroussi discloses every element of system claim 28. Seroussi's "run enhancement engine" was argued to meet the "run-length encoder" limitation. The system’s dictionary, which is used for both LZW compression and run detection, was mapped to the claimed "dictionary comprising a plurality of code words." Crucially, Petitioner argued that Seroussi's use of an "out of order" dictionary code to signal that a run has occurred met the "control code word" limitation. The core LZW compression engine was mapped to the "dictionary encoder," and the system's output engine, which produces a single stream of codes representing both dictionary matches and encoded runs, met the limitation that the outputs are "combined to form an encoded data stream."

Ground 3: Claim 28 is obvious over Seroussi in view of Nelson

  • Prior Art Relied Upon: Seroussi (Patent 5,389,922) and Nelson (The Data Compression Book, 1992).
  • Core Argument for this Ground:
    • Prior Art Mapping: As an alternative to anticipation, Petitioner argued that if Seroussi's "out of order" codes were deemed insufficient to meet the "control code words" limitation of claim 28, the deficiency is supplied by Nelson. Nelson, a standard textbook on data compression, was cited for its explicit teaching of using reserved dictionary indices as dedicated control codes in LZW implementations, such as codes to "Flush" (re-initialize) the dictionary, "Bump" the code size, or signal the "End of Stream."
    • Motivation to Combine: A POSITA would combine Seroussi with Nelson because both describe the well-known LZW compression algorithm. Since Seroussi already teaches a system that could benefit from enhanced controls like dictionary re-initialization, it would have been obvious to look to a standard textbook like Nelson to implement such features. Incorporating Nelson's dedicated control codes into Seroussi's LZW engine was argued to be a straightforward way to add known functionality.
    • Expectation of Success: A POSITA would expect success because adding pre-defined control codes to an LZW algorithm is a standard, well-documented technique for improving its functionality and control. Doing so in Seroussi's system would predictably result in a more robust compression engine.

4. Key Claim Construction Positions

  • "control code word" (Claim 28): Petitioner proposed this term be construed as "a dictionary index corresponding to a signal to a decoder." This construction was central to the arguments against claim 28, as it supported the contention that Seroussi’s use of an "out of order" dictionary code value (an index) to implicitly signal a run to the decompressor satisfied the limitation for a control code.

5. Relief Requested

  • Petitioner requests institution of an inter partes review and cancellation of claims 1, 9, 14, 22, and 28 of Patent 6,597,812 as unpatentable.